C.T. “Kip” Howlett,
Jr., Executive Director, Chlorine Chemistry Counciltestimony before the City Council Committee on Public Works and
the Environment on the DC Water and Sewer Authority and Its Lead Service
Replacement ProgramMarch 17, 2004

Before the Council of the District of Columbia
Committee on Public Works and the Environment

March 17, 2004

Good afternoon Madame Chair and members of the Committee
on Public Works and the Environment. I am Kip Howlett, Executive
Director of the Chlorine Chemistry Council, and a Vice President of the
American Chemistry Council. The Chlorine Chemistry Council is a national
trade association based in Arlington, Virginia representing the
manufacturers and users of chlorine and chlorine-related products. Safe
drinking water is a vital issue for CCC's member companies, who supply
chlorine both for water disinfection, and to manufacture PVC pipe used
in modem water infrastructure.

I appreciate this opportunity to speak to the Committee
today. I cannot offer any definitive answers on what is causing high
lead levels in some District homes, or provide an easy solution.
However, I can offer some important insight on the riskbenefit tradeoffs
involved. The ultimate solution is to get the lead out, while taking
necessary interim steps to protect public health.

Steps taken to reduce one risk must not increase other,
more serious risks

As this committee well knows, safe drinking water is one
of the most fundamental elements of public health protection. However,
water treatment and safe distribution is a complex process, and water
systems face a vast array of regulations, competing demands and
treatment options. Measures taken to improve one aspect of water quality
inevitably impact other aspects.

With the current lead contamination crisis, EPA, the
Washington Aqueduct, WASA and the City Council face a number of
challenges in balancing public health concerns. Will additional
corrosion control measures, particularly the use of zinc orthophosphate,
fully resolve the problem? Has the existing lead service line
replacement program actually worsened corrosion? If chloramines are
indeed exacerbating lead contamination, what would be the health and
regulatory implications of switching back to free chlorines for
secondary disinfection, at least temporarily?

EPA has recognized the importance of risk-benefit tradeoffs in
setting drinking water standards. For example, EPA carefully crafted
rules to reduce potential risks from disinfection byproducts without
compromising protections against hte far greater risks of microbial
contamination. The Agency was well aware of a catastrophe that occurred
in Peru in the early 1990s, when exaggerated fears about disinfection
byproducts led officials to reduce chlorination. Inadequate disinfection
of drinking water supplies contributed to a five-year cholera epidemic,
the disease's first appearance in the Americas in the 20th century, that
caused more than one million illnesses and 12,000 deaths. Current EPA
standards limit disinfection byproduct levels in drinking water with a
substantial margin of safety. As a new EPA study issued March 4th
concludes, alternatives to chlorination may actually form higher levels
of unregulated but potentially more tragic byproducts.

These examples highlight that any decision to change treatment
methods must consider overall impacts on microbial quality, chemical
parameters, and distribution system impacts. It is critical that steps
taken to reduce one risk do not increase more serious ones.

Chlorine is essential to delivering safe water

In 1997, Life magazine hailed drinking water chlorination as
"probably the most significant public health advancement of the
millennium." Before cities began routinely treating drinking water
with chlorine (starting with Chicago and Jersey City in 1908) typhoid
fever killed over 25,000 U.S. residents every year. Cholera, dysentery
and hepatitis A posed similar threats. Drinking water chlorination has
helped to virtually eliminate these diseases in the U.S.

Meeting the goal of clean, safe drinking water requires a
multi-step approach. Disinfection, unquestionably the most important
step in water treatment, is carried out in two stages, primary and
secondary disinfection. Primary disinfection removes harmful
microorganisms at the treatment plant. Although a number of alternatives
are available, chlorination is by far the most common method.

Chlorine is also used for secondary disinfection, which
provides a residual level of disinfectant to help protect treated water
as it travels to consumers' taps. Regardless of the primary treatment
method used, EPA requires water systems to maintain minimum residual
levels of either chlorine itself (free chlorine) or chlorine-based
compounds such as chloramines, in the distribution system.

Chloramines are an increasingly popular choice for
secondary disinfection

In November 2000, the Washington Aqueduct switched from
using free chlorine to chloramines for secondary disinfection. The
switch enabled the system to reduce the formation of certain
disinfection byproducts regulated by EPA, while maintaining protection
against waterborne disease.

Treatment plant operators form chloramines by applying a
specified amount of ammonia to drinking water, in addition to free
chlorine. Chloramine compounds are more stable than free chlorine. They
provide durable protection in long distribution lines, making them
excellent for secondary disinfection. Chloramines also control coliform
bacteria and biofilm growth on pipes, and are sometimes used to address
taste and odor problems. Because chloramines are less reactive than free
chlorine, using chloramines can reduce the formation of some
disinfection byproducts.

Chloramine use is not new. Denver, Colorado, for example,
has used chloramines since 1917. However, its popularity has increased
dramatically in recent years, as drinking water systems work to comply
with a range of new EPA standards, including the 1998 Stage 1
Disinfectants and Disinfection Byproducts Rule.

Currently, about 30% of U.S. water systems use
chloramines as secondary disinfectants. As a result of newly proposed
regulations (the Stage 2 Disinfectants and Disinfection Byproducts
Rule), EPA predicts that an additional 3% of water systems will shift to
chloramines.

As with any significant change to treatment practices,
switching from free chlorine to chloramines can pose challenges for a
water system. The potential effects of chloramine use on distribution
systems and household plumbing are not fully understood.

Did the switch to chloramines cause DC's high lead
levels?

Too many open questions remain to say definitively what
caused the excessively high lead levels in some DC homes. I share the
Committee's hope that the expert team assembled by EPA, WASA, and the
Washington Aqueduct will shed new light on these issues and recommend
both short and long term solutions.

As has been discussed, the primary sources of lead in
drinking water are components of the distribution system itself - lead
pipes, lead-based solder, and brass fixtures that contain lead. Given
the difficulty and expense of removing all sources of lead, EPA's Lead
and Copper Rule is intended to minimize corrosion through appropriate
treatment techniques, and prevent these metals from leaching into the
drinking water.

Clearly, the use of chloramines changes water chemistry,
and such changes can have dramatic effects on corrosivity. The addition
of ammonia at the treatment plant increases the level of nitrification
in water, which can lower pH in the distribution system. Such a change
requires an effective corrosion control program. It will be for others
to determine why corrosion control measures here were apparently
ineffective for the Washington, DC system, and what changes in water
treatment are needed now.

High lead levels in drinking water pose clear dangers to
public health, and these dangers must be considered on equal footing
with other potential risks from drinking water contaminants. Changes to
water treatment methods can affect microbial quality, chemical
parameters, and distribution systems. Therefore, decision makers must
have the flexibility to balance these competing concerns, and take
actions to minimize overall health risks.